Dear Mr. The CME Guy,
Since you are clearly the most knowledgeable, insightful, and – dare I say, dashing? – CME consultant in the Northwest Philadelphia region, I am hoping you can help clear up a situation that has cropped up for me recently. One of the accredited CME provider’s that I frequently partner with just told me that they are no longer providing the names of faculty when they submit grant applications for CME programs. They claim that this is due to a recent announcement from the ACCME, but I have no idea what they’re talking about. My question to you is: what up with that?
Perplexed in Poughkeepsie
Thank you for your not-at-all-made-up-as -a-device-for-a-blog-post email. Indeed, the issue of whether or not it is OK to include a list of faculty in CME grant submissions has gotten a bit muddled recently. The genesis of this discussion is likely the announcement from the American Academy of Physician’s Assistant’s that they would “no longer accredit CME talks receiving grant support from BI (Boehringer Ingelheim).” In that announcement, the AAPA states:
Anytime a grant application asks for the names of faculty, as BI’s currently does, it is out of compliance and cannot be accredited for CME.
This was news to many of us in the CME community as we, like you, were not aware that supplying faculty names when required to do so in grant applications was considered out of compliance with the ACCME’s Standards for Commercial Support. I talked with a number of experienced CME professionals about this issue and while some of them had stopped supplying faculty names due to their own internal policies, none of them was aware that doing so was a matter of noncompliance. There was also not a direct reference to this specific issue on the ACCME’s website. In an effort to clarify this matter, I – and I would imagine others, though I do not know that for certain – sent an email to the ACCME asking for guidance as to the compliance of providing faculty names in grant applications.
The response I received from the ACCME directed me to this recently created FAQ, that asks the question:
Can providers be required by potential commercial supporters to share the list of expected authors or speakers with commercial supporters, during the process of applying for an educational grant?
The short answer from the ACCME is “no”, confirming the statement from the AAPA’s announcement. However, I believe there are still two fairly important questions related to this issue that remain unanswered:
- What is the status of CME-certified activities for which funding was previously received via grant applications that required a list of faculty? Will they be considered noncompliant?
- Is it OK for CME providers to voluntarily provide a list of potential faculty names in a grant proposal/application? The ACCME’s FAQ specifically only mentions cases where a faculty list is required. This is splitting hairs, I realize, but it is a question that has been asked of me by a number of people.
I have attempted to follow-up with the ACCME for a response to these two questions, but have been unsuccessful in receiving a definitive answer. As such, I am left to form my own opinions, which is more fun anyway. As to the answer for Question #1, I really have no idea. A colleague of mine stated that she believes the best approach is to simply document that you did not make changes to your faculty based on a grant request, and move on. I tend to agree with her.
As to Question #2, I refer you to the ACCME’s response to the question “How should an accredited CME provider respond to a request by a commercial supporter to review materials for an upcoming CME activity?” It’s very similar to their response to the question about faculty lists (“No CME reason…”). Note that they only specifically mention the commercial supporter requesting the content review, but never mention a provider asking the commercial supporter to do a review. Again, similar to the faculty response. How many of us, though, believe that it’s OK for a CME provider to ask a commercial supporter to do a content review? My point is, I don’t think the ACCME is splitting hairs and saying it’s OK to supply a faculty list voluntarily, you just can’t do it if required to. I think, like content reviews, they’re saying you shouldn’t do it, period. But that’s just my opinion. I could be wrong.
I apologize for such a long-winded answer, but hope this has you feeling a little less perplexed in Poughkeepsie.